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Enron Mail |
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Content-Type: text/plain; charset=ANSI_X3.4-1968 Content-Transfer-Encoding: quoted-printable X-From: Shelley Corman X-To: Steven J Kean, Vicki Sharp, Drew Fossum, Maria Pavlou, Michael Moran X-cc: X-bcc: X-Folder: \Drew_Fossum_Dec2000_June2001_1\Notes Folders\All documents X-Origin: FOSSUM-D X-FileName: dfossum.nsf Enron Energy Services is presently a marketing affiliate of several of the= =20 Enron pipelines because EES: (1) buys/sells gas; and (2) holds transport=20 contracts on our pipelines. =20 Under the FERC's standards of conduct, the pipelines cannot: (1) share=20 transportation information or shipper information with EES; (2) must functi= on=20 independently and keep separate books and records. Generally, I don't see= =20 the FERC having any problem with mechanical, electrical, air-conditioning= =20 types of services. However; there are 2 specific concerns that arise with= =20 respect to the described arrangement under the FERC's marketing affiliate= =20 standards of conduct: 1. Records -- FERC has ruled that giving a marketing affiliate "access" to= =20 transportation and shipper records (including something as simple as file= =20 room access) is deemed to be impermissibly sharing the information with a= =20 marketing affiliate in violation of the standards. Thus, it seems to me tha= t=20 EES will explicitly not be able to perform any records management function= =20 for NNG, TW or NBPL. 2. Billing - FERC scrutinizes intercompany charges carefully. In a recent= =20 Kinder-Morgan consent order, the FERC used payroll and intercompany charge= =20 records to make the case that the pipeline and marketing affiliate did not= =20 operate separately. It would be helpful if any EES facility management=20 charges/allocations come from Enron Facility Services (not EES) -- leaving= =20 us room to argue that the facility management subsidiary involves separate= =20 functions and staff than the EES subsidiary that is a marketing affiliate. =20 =09 =09 =09From: Steve Kean & Bill Donovan 11/14/2000 06= :36 PM =09 Sent by: Enron Announcements To: All Enron Houston cc: =20 Subject: Reorganization of Houston and Omaha Facilities Management=20 Responsibilities Responsibility for daily operations of building support services in the=20 Enron Building, Houston leased offices, and Two Pacific Place (Omaha) will = be=20 transitioning from Corporate to Enron Energy Services (EES) by year-end. T= he=20 areas affected include facility operations and maintenance of mechanical,= =20 electrical, and air-conditioning systems; mail delivery; housekeeping; =20 food, copier, and records services. This transition of services, as presently managed by Enron Property and=20 Services Corp. (EPSC), is designed to optimize value to Enron=01,s Business= =20 Units by leveraging facility management businesses now offered by EES to=20 their commercial customers. EPSC staff having administrative responsibilit= y=20 for these services will report to Enron Facility Services, a subsidiary of= =20 EES=01,s Global Energy Services group led by Daniel Leff, President and CEO= . EPSC is responsible for Enron=01,s internal real estate and office developm= ent=20 needs, including leasing, space allocations and facility planning, project= =20 and construction management, furniture systems, and office relocation. EPS= C,=20 in its development role, remains a part of Enron Corporate Administration= =20 Services (ECAS) along with Corporate Security and the Aviation Department,= =20 reporting to Bill Donovan, Vice President, Corporate Administrative Service= s. This alignment of responsibilities offers the opportunity for EPSC to focus= =20 resources on effective utilization of our existing office space assets and= =20 managing the development of Houston=01,s new Enron Center Campus project.
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